Finding 1173698 (2022-006)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2026-02-16
Audit: 387410
Organization: YWCA Tulsa, Inc. (OK)

AI Summary

  • Core Issue: Insufficient documentation for expenses charged to the Federal award, including unallowable costs like late fees and gift cards.
  • Impacted Requirements: Noncompliance with 2 CFR 200.403(g) and 2 CFR 200 Subpart E, which mandate proper documentation and management of allowable costs.
  • Recommended Follow-Up: Establish procedures for reviewing costs charged to Federal awards, ensuring staff are knowledgeable about compliance and documentation requirements.

Finding Text

Compliance: Activities Allowed or Unallowed and Allowable costs – Documentation of Expenses and Indirect Costs Assistance Listing Numbers and Title: 93.566 Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Agency: U.S. Department of Health and Human Services Pass through Entity: Oklahoma Department of Human Services Pass through Entity Award Number: N/A Finding type: Noncompliance and Material WeaknessCriteria: Section 2 CFR200.403(g) requires that costs must be adeduately documented to be allowable under the terms and conditions of Federal awards. Management is responsible for implementing internal controls to ensure that costs charged to the award be allowable 2 CFR 200 Subpart E, Cost Principles, requires non-Federal entities to be responsible for the efficient and effecive administration of the Federal award through sound management practices. Allowable costs include those necessary and reasonable for the performance of the award. Condition: During the course of audit, several expense lacked sufficient documentation to support the expenditures charged to the Federal award, including giftcards. Other costs were charged to the Federal award that were not allowablable costs inlcuded late fees. In addition, we noted that indirect cost charged to this grant were based on total budget amount at a monthly increment, rather than a using actual 10% de minimis indirect cost rate. Cause: This award was new to the Organization in 2022 and administrative assignments were not established immediately and management lacked sufficient knowledge on grant and compliance requirements. Effect: Failure to properly document expenditures may result in the submission of unallowable costs and activities causing noncompliance with federal grant guidelines. Failure to properly calculated de minimus cost rate based on direct costs may result in noncompliance with federal grant guidelines.Questioned cost: Known $140,051 and Projected: Unknown. Recommendation: We recommend the Organization implement procedures that costs charged to Federal awards are reviewed by staff with knowledge of allowable activities and costs principles and costs are adequately documented.Management response: See corrective action plan on page 18.

Corrective Action Plan

Management's response: When the federal grant award came out at the end of December 2021 , we did not get an approved budget and signed contract for work with the State until the beginning of July 2022 for work that dated back to October 1, 2021 . Because we did not have a signed contract until so late into the grant {even though we knew the grant was coming and had already started the work to support Afghans as they arrived in Tulsa). we did not have full guidance or understanding as to how the funds had to be invoiced/spent. In March, we purchased gift cards for clients for immediate needs, and while we had sufficient documentation about the purchase of the gift cards, we did not have the back-up documentation that showed their distribution to clients. We also were not aware that the late fees could not be charged as they were incurred.Finally, as the work started, we knew that our overall indirect costs were greater than what was budgeted .Because we knew our costs were greater than the 10% budgeted, we simply billed the full amount budgeted towards indirect costs during each month, and failed to adjust based on actual direct costs invoiced to the grant. This was a misunderstanding on our part of how that budgeted item needed to be invoiced, and we have since corrected this. Views of Responsible Officials and Corrective Action : Immediately after receiving feedback from ouraudits about gift cards, we created an additional process where if we purchase or receive gift cards, we have team members check out those gift cards and include which clients the gift cards are going to so we can track those. Overall, we try not to utilize gift cards when possible, and have removed those purchases on federa l grants. We have also made sure to no longer include any late fees on grants moving forward, and have internal reviews from our Grants Accountant and Senior Director of Finance to help track for that. budgeted line item.Finally, in 2023, we fi xed our indirect cost billing to make sure that it matched our direct costs and not the budgeted line item. Name of Contact Person: Name:Julie Davis Title Chief Executive Officer Email: juliedavis@ywcatulsa.org Phone: 918-828-2346 Projected Implementation: The implementation is complete.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1173697 2022-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $2.16M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $230,729
97.010 CITIZENSHIP EDUCATION AND TRAINING $126,986
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $107,842
21.019 COVID-19 CORONAVIRUS RELIEF FUND $49,199
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $45,802
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $39,413
93.598 SERVICES TO VICTIMS OF A SEVERE FORM OF TRAFFICKING $8,288